virginia paving special use permit september 26, 2006€¦ · virginia paving special use permit...
TRANSCRIPT
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City Council Work Session
Virginia Paving Special Use Permit
September 26, 2006
Briefing by Office of City Attorney Department of Planning and Zoning Department of Transportation and Environmental Services
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I-495
Cameron Station
Backlick Run
S. V
an D
orn
Stre
et
Site
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Background
Office of City Attorney
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BACKGROUND
Plant has been in operation at present site since 1960Current Permits:
State Operating Permit (Feb 17, 2005)
State Stormwater Discharge Permit(Jul 01, 2004)
City Special Use Permit (Feb 10, 1960)
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BACKGROUND
City Special Use Permit (Feb 10, 1960)
“That no operation of this plant requiring exit or entrance of vehicles be permitted after hours of darkness or during inclement weather or on Sundays or holidays.”
Not an issue early on – night-time paving not prevalent at time plant was permitted and for many years thereafter.
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BACKGROUND
City Special Use Permit (Feb 10, 1960)
Paving practices changed - populations became more dense, traffic increased, paving technology changed and night-time paving became the preferred method
City did not enforce prohibition on night-time vehicular traffic – no complaints, plus no awareness of prohibition at time practices changed.
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BACKGROUND
SUP Enforcement by the City
Historically complaint-driven – very few complaints regarding plant prior to 2000
Current practice - City has changed Special Use Permit enforcement generally. Every site with an SUP will be reviewed for compliance at least once every three years, whether complaints are received or not
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BACKGROUND
Complaints/Concerns
After 2000, City began to receive more complaints in general vicinity of plant
Primarily odor complaints, not attributed to paving plant specifically
As time passed, the City also began to receive other complaints about soot, noise, smoke and air quality – again not specific to paving plant
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BACKGROUND
Complaints/Concerns
Communicated concerns to plant in October of 2004: water quality, fire code and other items, as well as 1960 SUP issues regarding night-time operations and settling basins.
Began to work with plant to correct code violations
Plant applied for amendment to its SUP in March 2005 to allow for night time vehicular traffic.
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BACKGROUND
June 2005 and June 2006 - City Council allows limited night-time vehicular traffic to plant for:
Specific City paving projects
Specific Woodrow Wilson Bridge paving
Emergency work
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BACKGROUND
Specific Community Concerns
Air Quality/Emissions – Is this “another Mirant?”
Noise
Traffic/Trucks
Water Quality
Proximity of plant to school/park
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BACKGROUND
18-month process during which City has:
Collected and shared information with applicant and communities closest to plant
Consulted with scientific experts
Researched and benchmarked with other jurisdictions
Formulated and negotiated with applicant and community proposed SUP conditions to reasonably address City’s and community’s concerns
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BACKGROUND
Large amount of work by numerous City departments to ensure fair, balanced process for both residents and applicant.
Proposed amended SUP terms give City far more control, particularly over air quality, than it would otherwise be entitled to under state and federal law.
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VIRGINIA PAVING SUP
Alternative is to go back to terms of 1960 SUP:
some storm water controls would be addednight time vehicular activity would stop
No extensive environmental controls as negotiated with the plant in the context of an amended SUP
Return to 1960 SUP terms would be a net loss for the City
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Planning Issues
Department of Planning and Zoning
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Enforcement and Land Use Policy
SUP Enforcement--Generally
Changed from complaint-based to proactive in 2005All SUPs now inspected every three yearsHierarchy of Enforcement:NoticeFinesHearingRevocation
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SUP Enforcement—Virginia Paving
Frequency of Inspections
Review and inspect every 6 months for the first 2 years and then annually thereafter
Targeted inspections to insure compliance with/implementation of date specific conditions
Inspections conducted in response to complaints
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Penalties for Noncompliance with SpecificConditions
Failure to comply with specific air quality conditions shall result in cessation of all night-time exit and entrance of vehicles from site; and
The SUP will be docketed for review and action by City Council within 30 days.
SUP Enforcement—Virginia Paving
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Community Outreach
Designation of Va Paving employee as compliance officer with name and phone number provided to City and community
Regularly scheduled meetings, at least once every 6 months, to discuss operations
SUP Enforcement—Virginia Paving
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Long-Range Planning for West End
Industrial land use and zoning historically in and around area of asphalt plant
Current planning effort underway for Landmark/Van Dorn area calls for retention of industrial uses
Planning for Eisenhower West area, to commence in 2007, will consider land use policies for industrially zoned uses in and around asphalt plant
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Environmental Issues
Department of Transportation and Environmental Services
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25
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Suggested Change to Conditions 25 & 28
We suggest that condition 28 remain as written, with the following added:
In particular, since the 24-hr. standard for the PM2.5 NAAQS has been revised from 65 ug/m3 to 35 ug/m3 (determined as the 98th percentile of three years of valid data), although thisNAAQS is not enforceable by EPA until the year 2015, the following conditions shall apply:
The City shall continue operating the PM10 monitor at Samuel Tucker School until three years of valid data have been collected.The City shall determine the 98th percentile of these data, per the NAAQS, and then multiply that value by 70%, to impute a 98th percentile value for PM2.5.If the imputed value exceeds 35 ug/m3, then the City reserves the right to require VA Paving to demonstrate that the facility is not causing this imputed exceedance.
We also suggest that Condition 25 be modified to add PM 2.5 to the list of emissions for which stack tests are required
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BACKGROUND
Air Monitoring at Cameron Station1991 through 1996No violations of TSP & PM-10 standardsNo metals detected in samples (Cd, Hg)
Comprehensive InspectionInspection done in Aug/Sep 2004City Attorney’s letter to VA Paving in Oct 2004Findings / Violations of current SUP
Nighttime OperationsLack of Settling Basin
Extensive environmental testing at the time of base closure
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Environmental Issues & Concerns
Raised by community since 2000Air Quality
EmissionsFugitive PM (dust)Ambient Impacts
OdorsNoiseLightingStormwater
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Environmental Review & Analysis
City’s Review / AnalysisEvaluated baseline emissionsPerformed dispersion modelingResearched stringent controls & best management practicesNegotiated the proposed SUP that goes beyond all current permits
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AIR QUALITY
Permitting ProcessVirginia DEQ has primary responsibilityClassified as Minor Source (< 100 tons/yr)
No modeling required for criteria or toxic pollutantsNo stack testing requiredNo ambient monitoring required
Burning of oil & recycled oil allowedCity’s Role: Local Ordinance, Special Use Permit
Other StatesStringent Controls (e.g., California)70-90% of asphalt plants burn Natural Gas
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AIR QUALITY - Emissions
Point Sources (NOx, CO, VOC, PM-10, PM-2.5, SO2)
Two Drum DryersTwo Asphalt HeatersLime Silo
Fugitive Sources (PM-10, PM-2.5)
RAP CrusherAggregate Handling (e.g., storage piles)
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AIR QUALITY - Emissions
SO2NOx
0
2,000
4,000
6,000
8,000
10,000
12,000
14,000
16,000
Tons
per
Yea
r
Emissions Comparison
PRGS
WTE
VPC
PM-10CO
VOC
0
100
200
300
400
500
600
700
Tons
per
Yea
r
Emissions Comparison
PRGS
WTE
VPC
SO2 NOx PM-10 CO VOCMirant PRGS 15,138.6 5,749.7 605.8 256.8 36.3Covanta WTE 206.0 830.0 106.0 145.5 9.1VA Paving 52.3 21.9 18.1 77.5 2.0
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AIR QUALITY - Modeling
Criteria pollutants modeledPM-10, PM-2.5NOx, CO, SO2
PbHazardous air pollutants modeled
VOC – acetaldehyde, acrolein, benzene,
1,3-butadiene, formaldehyde, quinone
PM –lead
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AIR QUALITY - Modeling
Pollutant Averaging
Period
Monitored Background
Concentration (µg/m3)
City’s Baseline Scenario (µg/m3)
City’s SUP Scenario (µg/m3)
VA Paving’s SUP
Scenario (µg/m3)
NAAQS (µg/m3)
CRITERIA POLLUTANTS
24-Hour 43 346 124 102 150 PM-10
Annual 19 35 30 25 50
24-Hour 35 125 58 68 65 PM-2.5
Annual 13 18 16 16 15
NOx Annual 45 74 63 54 100
1-Hour 4,580 7,467 5,817 5,202 40,000 CO
8-Hour 3,206 4,820 3,887 3,668 10,000
3-Hour 238 2,508 1,392 534 1,300
24-Hour 60 648 326 194 365 SO2
Annual 16 58 56 54 80
Lead Quarter 0.013 0.040 0.030 0.015 1.5
EPA has announced a new PM2.5 24 hr standard of 35 ug/m3 with 2015 attainment date
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AIR QUALITY - Modeling
Pollutant Averaging
Period
City’s SUP
Scenario (µg/m3)
VA Paving’s
SUP Scenario (µg/m3)
SAAC (µg/m3)
HAZARDOUS AIR POLLUTANTS
1-Hour 0.1 n/a 7.5 Lead
Annual 0.007 n/a 0.3 1-Hour 22.6 14.6 62.5
FormaldehydeAnnual 1.7 0.21 2.4 1-Hour 0.2 n/a 17.3
Acrolein Annual 0.02 n/a 0.46 1-Hour 0.09 n/a 1,100
1,3 Butadiene Annual 0.004 n/a 44 1-Hour 2.9 n/a 1,600
Benzene Annual 0.2 n/a 64 1-Hour 9.3 n/a 6,750
Acetaldehyde Annual 0.7 n/a 360 1-Hour 9.1 0.73 22
Quinone Annual 0.7 0.01 0.8
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New SUP – Limiting Operation
Production Cap900,000 tons/year until all new controls in place10,000 tons/day, 1,000 tons/hour
Hot Oil HeatersOnly one heater can operate at a timeOnly burn No. 2 oil (100,000 gallons/year)
Limited operation at night
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New SUP – Limiting Emissions
Blue Smoke Control (asphalt conveyor, loadout)
Low-NOx burners on dryersPM limit of 0.03 gr/dscf for baghouses0.05% sulfur in No. 2 oilLower constituent limits on recycled oilOther controls
Diesel engines - particle trapsAsphalt storage - condensers/filtersRAP Crusher – 80% PM control, 10% opacity
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New SUP – Limiting Impacts
Increase dryer stack height to 20 m
Increase hot oil heater stack height to 6 m
Only No. 2 oil in dryers during air quality action days
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New SUP – New Source Testing
PM test for baghouses, initially every 2 years
PM-10
NOx, SO2, CO test every five yearsBlue Smoke test upon installation
Demonstrate 99% control efficiency for particulate matter (PM-2.5 and PM-10)
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New SUP - BMPs
Best Management PracticesFrequent water spraying, vacuum sweepingPave eastern end of plantWater sprays on transfer pointsEnclosed conveyorsWetting or chemical suppressant for storage piles
Inspection and Recordkeeping for all BMPs
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ODOR
Liquid asphalt/asphalt product causes odorResident complaints since 2000New SUP requires:
Blue Smoke Control (asphalt transfer points, loadouts and silos)
Condensers & filters (asphalt storage)
Must prevent odor from leaving property
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New SUP – Lower Limits
Parameter State Limit SUP Limit 1,500,000 tons/year 1,200,000 tons/year No daily limit 10,000 tons/day Production No day/night restriction Only one dryer at night
Hot Oil Heater No. 2 & recycled oil No. 2 oil only No. 2 Oil 0.5% sulfur 0.05% sulfur Recycled Oil
SulfurArsenic
CadmiumChromium
LeadHalogens
PCB
0.5% 5 ppm 2 ppm 10 ppm 100 ppm
1,000 ppm 49 ppm
0.5% 3 ppm 2 ppm 7 ppm 50 ppm
1,000 ppm 2 ppm
Baghouse PM 0.04 gr/dscf 0.03 gr/dscf RAP Crusher Opacity 15% 10%
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AIR QUALITY – New Monitoring
City installed new PM10 monitorPermanent PM monitorLocation of new monitor based on:
ModelingAreas of concern (schools, residences, etc.)In consultation with community’s consultant & Virginia DEQ
Purpose of monitoring is to ensure compliance
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AIR QUALITY – New Monitoring Data
PM-10 24-hr Average Concentrations
0
20
40
60
80
100
120
140
160
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Sample No.
PM-1
0 (u
g/m
3)
Boothe Park (2004)Brenman Park (2004)Tucker School (2006)NAAQS
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NOISE
Sources of noise:Railroad delivery & unloadingTrucks (backup alarms, tailgate banging)
Aggregate handling equipmentRAP crusherIntercom speakers
Resident complaints regarding noise at night
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NOISE
New SUP requires:Must meet City’s Noise Control CodeNo amplified sound audible at property lineRail delivery/unloading during daytime onlyRAP crusher limited to daytime onlyMinimize truck backup alarms
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NOISE
New SUP requires:No tailgate banging (install signs)
No engine brakes on site (install signs)
Night operation limited to 1 dryer, 1 skid steer, 1 mobile crane, and trucks only as needed
City to review noise abatement measuresMay require a sound barrier
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LIGHT
Lighting issues:Nighttime operationBright area lights
New SUP requires:Adjust lights to eliminate glare (point downward)Only operate lights required for operation
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New SUP – Water Issues
Stormwater Management FacilityLocated on siteDesign to be approved by CityVA Paving to follow O&M proceduresCity-approved maintenance contract
Asphalt pile pulled back from streamVA Paving to stabilize stream bankVegetative buffer on West Park
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Stormwater BMPs Concept Plan
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VIRGINIA PAVING SUP
Alternative is to go back to terms of 1960 SUP:
some storm water controls would be addednight time vehicular activity would stop
No extensive environmental controls as negotiated with the plant in the context of an amended SUP
Return to 1960 SUP terms would be a net loss for the City